Harvey Taylor - Page 4

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          insurance plan.  However, petitioner did not directly pay any               
          other expenses for the children on a routine basis.                         
               During the year in issue, Ms. White lived in a three-bedroom           
          apartment with the four children.  She was employed part time as            
          an assisted living care provider, and she received approximately            
          $1,500 per month in welfare and Social Security income.  The                
          children were covered by a State medical insurance program.  Ms.            
          White estimated her monthly expenses during that year to be as              
          follows:  $575 for rent, $100 for utilities, $40 for life                   
          insurance, $45 for telephone service, $300 for food, and $280 for           
          a car payment and car insurance.  Because two of petitioner’s and           
          Ms. White’s children are developmentally disabled, Ms. White must           
          incur additional expenses.                                                  
               The first issue for decision is whether petitioner is                  
          entitled to four dependency exemption deductions.  Petitioner               
          claimed dependency exemption deductions for Tristan, Harvey,                
          Khyrie, and Kares.  Respondent disallowed each of these                     
          deductions.                                                                 
               Among other requirements, a taxpayer generally is entitled             
          to a dependency exemption deduction for a child only if the                 
          taxpayer provides over half of the child’s total support during             
          the taxable year.  Secs. 151(a), (c) and 152(a).  The total                 
          support for a child includes the entire amount of support which             
          the child receives from all sources, including Social Security              






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